ML19305D032
| ML19305D032 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/17/1980 |
| From: | Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| Shared Package | |
| ML19305D027 | List: |
| References | |
| NUDOCS 8004110567 | |
| Download: ML19305D032 (18) | |
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M2rch 17, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Cocket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
LICENSEE'S RESPONSE TO INTERROGATORIES (FIFTH SET) OF THREE MILE ISLAND ALERT, INC.
INTERROGATORY NO. 1 Has Licensee engaged the services of independent contractors to perform or supplement the performance of maintenance, repair or quality' assurance functions at Three Mile Island? -
INTERROGATORY NO. 2 .
If so, state:
(a) the names, addresses and telephone numbers of each contractor who has been engaged by the Licensee since 1975; ,
(b) the dates during which services were provided; P
(c) copies of executed contracts between Licensee and the contractors; (d) copies of waivers executed by any contractor or by '
Licensee or both relating to radiation exposure of workers, hours of employment in radioactive areas of ,
the plant, Nuclear Regulatory Commission regulations or guidelines or liability for injury or suit 'or any other document that could fairly be characterized as a waiver relating to such contractors or contracts; .
(e) provide the names, addresses and telephone numbers-of all individuals performing maintenance, repair or quality '
assurance functions as of ficers, agents, or employees of such contractors and provide dates of employment and a description of responsibilities; 8004110 % 9 r
INTERROGATORY NO. 2 (cont.) -
(f) provide any evaluations or reports prepared by Licensee or in Licensee's possession which relate to work per-formed under such contracts; (g) with regard to such contracts or contractors, explain on '
what basis determinations were made to engage independent contractors as opposed to the employment of Licensee's own workers and provide copies of any reports, evaluations, or analysis of how such decisions were arrived at or that explain the rationale of Licensee in making such deter-minations; (h) provide copies of all reports requested or required by Licensee from contractors which document the work performed and the payments required to be paid for such work; (i) provide any documents or summaries of documents which show the hours worked at TMI by individual employees of the contractors.
RESPONSE (INTERROGATORIES 1, 2)
(a) Licensee has engaged the services of the following independent contractors to perform maintenance, repair and associated quality assurance rel,ated to safe operation of TMI 1 and 2; Bell of Pennsylvania (215) 820-4400 Suite 115, 1501 Cedar Crest Blvd.
Allentown, PA 18104 Burns and Roe, Inc. (201) 265-2000 550 Kinderkamach Road Oradell, NJ 07649 Catalytic, Inc. (215) 864-8000 Center Square West 1500 Market Street Philadelphia, PA 19102 .
Nuclear Energy Services, Inc. (203) -748-3581 Shelter Rock Road Danbury, CT 06810 Crouse Nuclear Energy Services (215) 248-4340 Upper Lewis Road Linfield, PA 19468 l
Furman.4r_
. .c . (804) 486-8182 529 Viking D'Ive Virginia Buch, VA 23452 General E.' ;ctric Company (215) 241-5361 Three Per4 Center Plaza Philadel hia, PA 19102 C. C. 'attcamp and Son, Inc. (717) 845-7611 515 W'at Market Street '
York, PA 17404 Mercury Company of Norwood, Inc. (617) 583-4880 '
10 Burke Drive P.O. Box 1687 Nuclear Support Services (301) 948-7010 l Suite 13A 13901 Jeff Davis Highway Woodbridge, VA 22191 Universal Testing Laboratories, Inc. (201) 239-9090 579 Pompton Avenue Cedar Grove, NJ 07009 VSL Corporation (408) 354-6481 236 North Santa Cruz Avenue Los Catos, CA 95030 ,
Westinghouse,"Inc. (215) 667-7600 Power Generation Service Division .
1974 Sproul Road Broomall, PA 19008 (215) 564-5293 Babcock and Wilcox Three Penn Center Plaza Philadelphia, PA 19102 Vikonics, Inc. (212) 686-4152 23-25 East 26th Street New York, New York 10010 Walsh Instrumentation, Inc. (412) 787-7920 209 Parkway View Drive Parkway West Industrial Park Pittsburgh, PA 15205 (b) The period of performance for the work of these ~ independent contractors is set forth in their. respective contracts.
(c) Copies of the contracts will be placed in Licensee's Discovery Reading Room.
(d) Waivers, if any, would be included as part of the conditions and provisions of the contracts being provided.
(e) A list of the contractors' craft personnel which provides the name and address of the individuals will be placed in Licensee's Discovery Reading Room.
(f) Evaluations and reports prepared by Licensee or in Licensee's possession are QC Inspection Reports, QC Surveillance Reports and QA Audic Reports. Copies of these reports retained by Licensee will be placed in Licensee's Discovery Reading Room. .
(g) Independent contractors were engaged for maintenance,
, repair and quality assurance in the 'following principal areas for the reasons stated:
(1) Vendors or designers - As the supplier or designer of equipment or systems (e.g., General Electric Company -
turbine vendor) an independent contractor was at times more qualified than Licensee to perform necessary repair and maintenance work due to its expertise, familiarity and experience with the design, construction, operation, repair and maintenance of particular com-ponents, equipment or systems. In addition, a major consideration is that the use of independent contractors is often more cost-efficient than for Licensee to maintain, a permanent staff of similar type employees. The
contractors are frequently engaged for jobs of only relatively short duration such as refueling outages (usually six to eight weeks). 1 (2) Engineers and Skilled Technicians - From time to time the need arises to engage outside engineering and quality assurance to provide additional engineers and skilled technicians. Engineering firms are relied upon for assistance on particular maintenance or repair jobs, primarily during plant refueling outages. These engineering firms augment the technical expertise available from in-house i resources. This support is considered necessary due to ,
either the nature of the required work or the demands placed l upon Licensee's own staff during certain short time periods.
- i Independent skilled technicians in such fields as quality assurance are also engaged (primarily during refueling outages) to augment Licensee's own staff. Again, a prime consideration is that it is more cost-efficient to use outside contractors during peak work periods rather than maintaining the lavel of employees that would obviate the need for outside assistance.
(3) Independent Skilled Craftsman - Certain contractors have access to large manpower pools of craftsmen such as
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pipefitters , electricians , carpenters , mill righto ,
ironworkers, boiler makers, painters, asbestos workers, sheet metal workers and common laborers. These con-tractors (e.g., Catalytic, Inc.) have collective bargaining agreements with the various union halls
whereas Licensee does not. For Licensee to hire permanently the numbers and types of craftsmen to meet its peak job requirements would be economically prohibitive.and managerially unsound. Therefore, since manpower requirements fluctuate widely with maximum demand (300-400 additional men), occurring in the refueling outage mode, it is far more. cost -
effective for Licensee to engage outside contractors during these relatively short periods.
Prior to the refueling outage, the various items that need to be worked on are reviewed and estimates are made regarding the numbers and types of skills that will be required. Based on this scoping effort, each job is planned for either Licensee's own employees or outside contractor workers, depending on the nature of the job and other . scheduled work.
In addition, the need arises for work of such a limited nature (e.g. , sheet metal work, boilermaker work, insulation work) that it would not be economically prudent for Licensee to hire these types of crafts-men on a permanent basis.
Copies of any reports, evaluations or analysis per-taining to the rationale in engaging outride con-tractors will be placed in Licensee's Discovery Reading Room.
7-(h) (i) To the extent such information exists for the realevant time period i' is contained in 266 reels of microfilm and.tver 25 file cabinets located at Licensee's office in Reading, Penn-sylvania. These documents will be made available to TMIA for its review and copying at Licensee's offices in Reading, Pennsylvania.
, INTERROGATORY NO. 3 Provide copies of any evaluations, analyses or. reports with regard to the working conditions, performance of employees or complaints of any of Licensee's employees engaged in the maintenance, repair or quality assurance function at Three Mile Island regarding working conditions or hours.
RESPONSE
Licensee's information concerning evaluations, analyses and reports with regard to working conditions, performance of employees or complaints is reflected in the following documents:
Grievance Reports Records of Disciplinary Actions Employce Attitude Survey Report Good Housekeeping Reports copies of these documents will be placed in Licensee's Discovery Reading Room.
INTERROGATORY NO. 4 With regard to the " economy and production group" described at Page 20 of the deposition of Larry Lawyer given to the President's Commission on ;
1 Three Mile Island, please provide the following information:
(a) a description of the purpose of the group, including any contemporaneous memoranda establishing the group or describing its function; (b) the names of all individuals constituting the group; (c) the date the group was established and l whether it is still functioning; (d) copies of all reports, analyses, memoranda or similar material provided by this group which contain recommendations or descriptions of its activities.
RESPONSE >
(a) These documents whien provide the purpose of the group and its establishment will be placed in Licensee's Discovery Reading Room.
(b) The individuals conctituting the group were Norman Williams, John Ulrich, Henry Yamamoto and Diane Shamis.
1 (c) The group, which is no longer functioning, was established in January 1977. l (d) The documents concerning this group will be placed in Licensee's Discovery Reading Room.
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INTERROGATORY NO. 5 With regard to the cut in the maintenance budget for 1979 described at Page 64 of the Deposition of Daniel Shovlin taken by the President's Commission on Three Mile Island, please provide the following:
(a) A detailed description of the budget cut and its impact both with regard to in-house maintenance and contracted maintenance; (b) all contemporaneous memoranda, reports or analyses which relate to this budget cut including memoranda recommending the cut, discussing it or approving it.
RESPONSE
(a) The following items were identified for reduction at TMI:
Budget Amount of 1979 Title of Reduction Affected Reduction
- 1. Catalytic work force re- TMI#1 S160,000 l duction to zero after re- (of $210,000 fueling outage for operation budgeted)
& maintenance items (to be i implemented approximately after April 1, 1979) 1
- 2. Gilbert Associates, Inc. Tech $67,000 Support During Refueling (of $317,000 budgeted for refueling tech ,
nical support) r
- 3. Reduce corrective maintenance TMI#1 $60,000 performed by Catalytic during (of $380,000 refueling budgeted)
- 4. Reduce scope of turbine gen- TMI#1 $200,000 erator inspection (do not do (of $368,000 B&C sections of low pressure budgeted) during refueling)
- 5. Reduce preventive main- TMI#1 $37,000 tenance on instrumentation (of $92,000 during refueling (Mercury) budgeted)
Budget Amount of 1979 Title of Reduction Affected Reduction
- 6. Reduce mechanical & TMI#1 $131,000 electrical corrective (of $162,000 budgeted) maintenance during refueling (Catalytic)
- 7. Assign six (Corporate TMI#1 $15,000 Technical Support Staff) engineers temporarily to TMI during refueling TOTAL $690,000 (b) Copies of the documents will be placed in Licensee's Discovery Reading Room.
INTERROGATORY NO. 6 Please provide for inspection of the Corrective Maintenance Component History Reports - Unit 1 - for the periods January 1, 1977 to September 28, 1978 and for March 28, 1979 to January 1, 1980.
RESPONSE
Licensee's Corrective Maintenance Component History Report -
Unit 1 covering the requested time periods will be placed in Licensee's Discovery Reading Room.
INTERROGATORY NO. 7 Which of the following employee / hour summaries does the Licensee maintain:
A. Weekly Recap; B. Monthly Earnings Summary; C. Year to Date Register; D. Master File Listing.
For those which are maintained, provide a copy of each summary for the period 18 months prior to the accident.
For those not maintained, describe the system used to summarize the hours worked by individual employees and provide a copy of this summary for the period 18 months prior to the accident.
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RESPONSE
A. Licensee maintains a " Weekly Recap" since August 1, 1978 in the form of Metropolitan Edison Company Time Sheet Recap. However, prior to that time , no such recap was maintained.
B. Licensee maintains a " Monthly Earnings Summary" as Metropolitan Edison Company Payroll Register (Weekly and Monthly).
C. Licensee maintains " Year to Date Register" as Weekly Payroll Overti?.le Hours Worked and Monthly Payroll Overtime Report.
D. Licensee does not maintain a " Master File Listing" or similar document.
Copies of the foregoing identified documents will be placed in Licensee's Discovery Reading Room.
I INTERROGATORY NO. 8 What are the account numbers assigned to the following systems in TMI Unit 1:
(a) Valves in the containment building; (b) Pressurizer level transmitter; (c) Hydrogen recombiner; (d) Pressurizer heaters; (e) Make-up pump switches; (f) Condensate polishers.
INTERROGATORY NO. 9 If an account number is not assigned to a particular item listed in Interrogatory 8 above, give the account number and description of the system in which the item is included.
RESPONSE
Licensee did not have a hydrogen recombiner installed in TMI Unit 1 prior to March 28, 1979.
There are no specific account numbers assigned to the valves in the containment building, pressurizer level transmitter, pressurizer heaters, make-up pump switches and condensate polishers. Rather, these items are part of the following classifications and account numbers:
(a) Valves in the containment building:
Routine Preventive Maintenance January 1, 1979 Prior to to March 28, 1979 January 1, 1979 Reactor Plant Reactor Equipment T6602/530.1 T8003/530.1 and Auxiliary Systems Heat Transfer System T6602/530.2 T8003/530.2 Fuel and Control Rod, T6602/530.3 T8003/530.3 Handling and Storage Radwaste Equipment T6602/530.4 T8003/530.4 Ventilation System T6602/530.5 T8003/530.5 j Instrumentation and T6602/530.6 T8003/530.6 Control Feedwater, Water T6602/530.7 T8003/530.7 Treatment and Service Water Systems Equipment Miscellaneous Reactor T6602/530.9 T8003/530.9 Plant Equipment Emergency Maintenance Heat Transfer Systems T6681/530.2 T8003/530.2 Fuel and Control Rod, T6681/530.3 T8003/530.3 Handling and Storage Radwaste Equipment T6681/530.4 T8003/530.4-
. Ventilation System T6681/530.5 T8003/530.5 i ,
January 1, 1979 Prior to to March 28, 1979 January 1, 1979 -
Instrumentation and T6681/530.6 T8003/530.6 Control Feedwater, Water T6681/530.7 T8003/530.7 Treatment, Service Water Systems Equipment Miscellaneous Reactor T6681/530.9 T8003/530.9 Plant Equipment Routine Corrective Maintenance Boilers and Auxiliary / T6721/530.1 T8003/530.1 Reactor Plant-Reactor Equipment and Auxiliary i Systems Heat Transfer Systems T6721/530.2 T8003/530.2 l Fuel and Control Rod, T6721/530.4 T8003/530.4 I Handling and Storage :
I Radwaste Equipment T6721/530.4 T8003/530.4 Ventilation System T6721/530.5 T8003/530.5 Instrumentation and T6721/530.6 T8003/530.6 Control Feedwater, Water T6721/530.7 T8003/5'O.7 ,
Treatment, and' Service Water Systems Equipment Miscellaneous Reactor T6721/530.9 T8003/530.9 Plant Equipment (b) Pressurizer level transmitter:
Routine Preventive Maintenance .
Instrument and Control: T6602/530.6 from 1/1/79'to 3/28/79 and T8003/530.6 prior to 1/1/79.
Emergency Maintenance Instrument and Control: T6681/530.6 from 1/1/79 to 3/28/79 and T8003/530.6 prior to 1/1/79.
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Routine Corrective Maintenance Instrument and Control: T6721/530.6 from 1/1/79 to 3/28/79 and T8003/530.6 prior to 1/1/79.
(d) Pressurizer heater:
Routine Preventive Maintenance i Heat Transfer System: T6602/530.2 from 1/1/79 to 3/28/79 and T8003/530.2 prior to 1/1/79.
Emergency Maintenance Heat Transfer System: T6681/530.2 from 1/1/79 to 3/28/79 !
and T8003/530.2 prior to 1/1/79.
Routine Corrective Maintenance Heat Transfer System: T6721/530.2 from 1/1/79 to 3/28/79 and T8003/530.2 prior to 1/1/79 (e) Make-up pump switches:
Routine Preventive Maintenance Reactor Equipment and Auxiliary System: T6602/530.1 from 1/1/79 to 3/28/79 and T8003/530.1 prior to 1/1/79.
Emergency Maintenance -
Reactor Equipment and Auxiliary Systems: T6681/530.1 from 1/1/79 to 3/28/79 and T8003/530.1 prior to 1/1/79.
Routine Corrective blaintenance Reactor Equipment and Auxiliary Systems: T6721/530.1 from i 1/1/79 to 3/28/79 and T8003/530.1 prior to 1/1/79.
(f) Condensate polishers:
Routine Preventive Maintenance Feedwater, Water Treatment and Service Water Systems Equipment: T6602/530.7 from 1/1/79 to 3/28/79 and T8003/530.7 prior to 1/1/79.
. Emergency Maintenance Feedwater, Water Treatment and Service Water Systems Equipment: T6681/530.7 from 1/1/79 to 3/28/79 and T8003/530.7 prior to 1/1/79.
Routine Corrective Maintenance Feedwater, Water Treatment and Service Water Systems Equipment: T6721/530.7 from 1/1/79 to 3/28/79 and T8003/530.7 prior to 1/1/79.
INTERROGATORY NO. 10 For each account number given in response to Interrogatory 7 or-8 above, how many regular and overtime hours were accounted to maintenance and repair for the period 18 months prior to the accident?
INTERROGATORY NO. 11 Does the Licensee maintain a labor-repair summary which summarizes the weekly, monthly or yearly hours devoted to each account number for maintenance / repair.
If not, describe the system used for the purpose of summarizing such information.
RESPONSE
The regular and overtime hours, summarized monthly, are reflected in TMI-l Regular and Overtime Summary which report will be placed in Licensee's Discovery Reading Room.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By / - /
Ernest L. Blake, Jr.
Dated: March 17, 1980.
k UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION P
r BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i In the Matter of )
)
METROPOLITAN EDISON COMPANY ,' Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1 )
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response To Interrogatories (Fifth Set) Of Three Mile Island Alert, Inc."
were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 17th day of March, 1980.
h / d /[d'd /
Ernest L. Blake, Jr.
f Dated: March 17, 1980.
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- UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND L10ENSING BOARD 1
l In the Matter of ) [
) l METROPOLITAN EDISON COMPANY ) Docket No. 50-28) !
) (Restart)
(Three Mile Island Nuclear ) ;
Station, Unit No. 1) ) t i
SERVICE LIST !
i Ivan.W. Smith, Esquire John A. Levin, Esquire ;
Chairman Assistant Counsel
'. Pennsylvania Public Utility Comm.l Atomic Safety and Licensing Board Panel Post Office Box 3265 l U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 ,
Washington, D. C. 20555 j
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Karin W. Carter, Esquire -
Dr. Walter H. Jordan Assistant Attorney General ;
i Atomic Safety and Licensing 505 Executive House ~
Board Panel 101 South Second Street
'881 West Outer Ridge Harrisburg, Pennsylvania '17120 i Oak Ridge, Tennessee 37839 l Dr. Little W. Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners Board Panel Dauphin County Courthouse j 5000 Hermitage Drive Front and Market Streets !
Raleigh, North Carolina 27612 Harrisburg, Pennsylvania. 17101 James R. Tourtellotte, Esquire Walter'W. Cohen, Esquire Office'of the Executive Legal Consumer Advocate Director Of fice of Consumer Advocate [
U.S. Nuclear Regulatory Commission 14th Floor, Strawberry Square [
Washington, D. C. 20555 HarrisbtcS, Pennsylvania ~17127 i Docketing and Service Section Jordan D. Cunningham, Esquire Office of the Secretary Attorney for Newberry Township U.S. Nuclear Regulatory Commission T.M.I. Steering Committee
, Washington, D. C. 20555 2320 North Second Street Harrisburg, Pennsylvania 17110 Theodore A. Adler, Esquire Widoff Reager Selkowitz & Adler Ellyn R. Weiss, Esquire Post Office Box 1547 AttorneyJfor the Union of Concers Harrisburg, Pennsylv'ania 17105 Scientists Shelden, Harmon & Weiss 1725 I:ye Street, N . W . , . Suite 5 0(.
Washington, D.-C. 20006
.- Steven C. Sholly 304 South Market Street Mechanicsburg, Pennsylvania 17055 Gail Bradford Holly S. Keck Legislation Chairman Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404 Karin P. Sheldon, Esquire Attorney for People Against Nuclear Energy Sheldon, Harmon &, Weiss 1725 Eye Street, N. W., Suite 506 -
Washington, D.C. 20006 Robert Q. Pollard Chesapeake Energy Alliance 609 Montpelier Street Baltimore, Maryland 21218 Chauncey Kepford Judith H. Johnrud Environmental Coalition on Nuclear Power 433 Orlando Avenue.
1 State College, Pennsylvania 16801 Marvin I. Lewis 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 Majorie M. Aamodt R. D. 5 Coatesville, Pennsylvania 19320
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